Opinion
13452-20
12-20-2021
Hillside Holdings, LLC, Inland Capital Sierra Holdings, LLC, A Partner Other Than the Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
By Order served August 30, 2021, the parties were directed to show cause in writing why this case should not be dismissed for lack of jurisdiction consistent with I.R.C. section 6226(b)(4). On September 9, 2021, petitioner filed a response to the Court's Order, in which petitioner failed to show cause why this case should not be dismissed for lack of jurisdiction. On September 10, 2021, petitioner filed a first amendment to his response, in which he also failed to show cause why this case should not be dismissed for lack of jurisdiction. On September 16, 2021, respondent filed a response to the Court's Order, in which he failed to show cause why this case should not be dismiss for lack of jurisdiction.
Premises considered, it is
ORDERED that the Court's Order to Show Cause dated August 30, 2021, is hereby made absolute. It is further
ORDERED that this case is dismissed for lack of jurisdiction on the ground that a prior petition was filed in respect to Hillside Holdings, LLC's 2016 tax year.